Anti-bribery policy

Our anti-bribery policy. It exists because s.7 of the Bribery Act 2010 — failure of a commercial organisation to prevent bribery by an associated person — applies to Pocket Docket Ltd with no size threshold and no de minimis. An "associated person" expressly includes agents and intermediaries, which is what a referral partner is.

The only defence to a s.7 charge is proving the organisation had adequate procedures in place. The Ministry of Justice guidance is explicit that a very small business does not need the procedures of a multinational — but the procedures have to exist before the incident, not be assembled after it. That is the entire reason this policy is dated. The risk assessment and partner due-diligence records that sit behind it are kept internally.

(For completeness: the Economic Crime and Corporate Transparency Act 2023 failure-to-prevent-fraud offence does not apply — it is limited to large organisations meeting two of three thresholds: 250+ employees, £36m turnover, £18m total assets. The substantive Fraud Act offences apply to everyone regardless of size.)

A. Anti-Bribery and Corruption Policy

Pocket Docket Ltd · company number NI742827

1. Our position

Pocket Docket Ltd does not offer, promise, give, request, agree to receive or accept a bribe. Not to win business, not to keep it, not to speed anything up, and not in any country.

This applies to everyone acting for us or on our behalf: the director, any employee, any contractor or consultant, and any referral partner.

2. What counts

A bribe is a financial or other advantage offered, given or accepted to induce or reward someone performing a function improperly — that is, in breach of an expectation that they will act in good faith, impartially, or consistently with a position of trust they hold. It does not have to be money and it does not have to be large.

Two things people commonly get wrong, and both matter here:

You can commit an offence without intending to. Under s.2 of the Act, in Cases 4 to 6 it does not matter whether the recipient knows or believes that the performance is improper.
A properly disclosed and consented payment is not a bribe. There is no improper performance where the person being influenced has told their own principal about the payment, that principal has consented, and the advice given is defensible on its own merits. Transparency is what separates a legitimate commission from an offence.

3. Facilitation payments

We do not make them. There is no exception for small sums, local custom or convenience.

4. Gifts and hospitality

Reasonable and proportionate hospitality given openly in the ordinary course of business is permitted. Anything that could reasonably be seen as intended to influence a decision is not.

Threshold: anything with a value over £100 given or received by or on behalf of Pocket Docket Ltd must be recorded in the gifts and hospitality log and approved by the director in advance. Cash and cash equivalents are never given or accepted, at any value.

5. The principal risk in this business, named

The referral programme is the principal bribery risk Pocket Docket Ltd faces, and it is the reason this policy exists.

We pay accountancy and bookkeeping practices a commission to introduce their own clients to our product. Those practices owe professional duties to those clients. If a partner takes our money without telling their client, our payment may induce the improper performance of a professional duty — and a reasonable person in the UK would certainly expect an accountant recommending software to a client to do so impartially and to disclose any payment from the vendor.

Our controls are set out in the Referral Partner Agreement and in the Client Disclosure and Consent Notice that forms part of it. The most important of them is that disclosure and client consent are a condition precedent to any commission becoming payable at all — no consent record, no commission, ever.

6. Reporting

Anyone who suspects a breach of this policy — by us, by a partner, or by anyone dealing with us — should report it to the director immediately at [email]. Nobody will suffer any detriment for raising a concern honestly, including if it turns out to be mistaken.

7. Consequences

A breach by an employee or contractor is a disciplinary matter and may be a criminal offence. A breach by a referral partner is a ground for immediate termination, clawback of all commission paid, and — where a professional duty is engaged — notification to the partner's professional body.

8. Review

This policy is reviewed at least annually by the director, and whenever the referral programme changes materially. The review is recorded and dated in Part B.

Signed: ......................................................... Name: ......................................................... Director, Pocket Docket Ltd Date: .........................................................

Version 1.0 · in force from 21 August 2026